Compensatory afforestation scheme framed by the Government of Kerala is adequate and sufficient. Occupants/encroachers are liable to pay compensation for the injury caused by them to the general public in view of "Polluter Pays Principle" . State Government shall determine the quantum of injury and amount of compensation payable in consultation with the Forest and Revenue Departments. Steps taken to issue of title deeds to occupants/encroachers are not opposed to Art. 48A and 51A of the Constitution.
[Nature Lovers Movements' vs. State of Kerala. O.P.No. 14276/1993, Dated 7-10-1999. P.A.Mohammed , G.Sivarajan and M.R.Hariharan Nair